JUST across the New Jersey Turnpike from Newark International Airport, workmen are installing artificial rocks and other finishing touches for Jersey Gardens, a two-level, 1.3 million-square-foot discount shopping mall.

New Jersey can hardly be said to be lacking for opportunities to shop. But executives of Glimcher Realty Trust, a Columbus, Ohio, company that is building Jersey Gardens, say this mall will be so different from the others that carpet the state that it will draw visitors from around the world.

Indeed, they are planning to run shuttle buses to the airport so that people visiting the area or who have a few hours of layover time can go to the stores. Jersey Gardens is scheduled to open on Oct. 21.

''This mall is different from the typical suburban mall where you run in, buy some pantyhose and leave,'' said Denise Palazzo, Jersey Gardens' general manager. ''You plan to visit here and most people will spend three or four hours. We want to create a family environment, a sort of mini-Disney.''

Jersey Gardens is an outlet mall, an outgrowth of the outlet stores that manufacturers and retailers once used to sell production overruns and out-of-season merchandise, and that has now grown to a market segment of its own. Glimcher officials say everything will be priced at least 30 percent below the regular retail price.

Kurt Barnard, president of Barnard's Retail Trend Report, said that most outlet stores functioned mainly as a means of disposing of outdated and slow-selling merchandise, although some manufacturers produced goods specifically for outlets. He said that, for the most part, consumers appreciate the chance to find a retail gem.

''Outlets have become a fixture on the American shopping scene,'' he said. ''If they did not offer what people want, they would not stay open very long.''

Shelly Mandel, a housewife and self-described serious shopper who lives in West Orange, N.J., said shoppers were wrong to assume everything in an outlet store was a good value. ''You have to be informed,'' she said. ''You have to know the merchandise and you have to know prices.''

One of the lures of outlet malls is the use of familiar retail names to suggest that the merchandise being offered is similar to what is being sold for full price in downtown stores. Some of the tenants who have signed leases at Jersey Gardens are Neiman Marcus Last Call, Off 5th-Saks Fifth Avenue Outlet, Brooks Brothers, Mikasa Factory Store, Burlington Coat Factory and Old Navy. In all, the mall is expected to have more than 190 retailers.

Convincing the public that it is getting a bargain can be a tough business. Last week, one of the pioneers in the field, Filene's Basement, filed for bankruptcy protection. Earlier this year, another venerable name in the off-price apparel business, Loehmann's Inc., also filed for bankruptcy protection.

Michael Glimcher, executive vice president of the real estate investment trust that is developing the center, said it would be different from typical suburban malls. For one thing, it will have its own entrance at Exit 13A of the turnpike via a $140 million overpass that will deposit motorists directly into its parking lot.

''This is a retail and entertainment destination that people will visit the way they visit resorts in Las Vegas,'' Mr. Glimcher said. In addition to a tree house and other child-oriented attractions in the mall, the Jersey Gardens project includes as freestanding 22-screen Loews cinema that will have dining and reserved seating with wider seats and aisles on second-floor balconies.

Mr. Glimcher said the mall would be sufficiently different from conventional shopping areas that it would not directly compete with them. ''We are not out to take customers away from other malls,'' he said. ''We just want to borrow them occasionally -- say once a quarter.''

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Real estate executives said Glimcher was benefiting from the difficulties the better-known Mills Corporation had encountered in trying to build a similar outlet center to the north in the Meadowlands. Although Mills has successfully developed massive discount malls in other parts of the country, its plans to fill in wetland in the much-abused Meadowlands has been stalled due to environmental concerns.

Jersey Gardens has also been supported by state financing of the direct link to the turnpike, which means prospective shoppers will be able to drive directly to the shopping without having to navigate the streets of an industrial area of Elizabeth. Although Glimcher will pay the $130 million in bonds sold to finance the connection through property tax payments, it was spared the need to raise the cash itself.

''The whole key was getting that exit from the turnpike so the mall can capture transient traffic,'' said Richard W. Latella, a senior director of Cushman & Wakefield, a real estate services company hired to appraise the site, a former landfill. He said that, because New Jersey does not have a sales tax on clothing and shoes, the mall is expected to attract shoppers from New York City, where those purchases are now taxed at 8.25 percent. The New York Legislature, however, has reached an agreement to eliminate the sales tax on clothing beginning March 1.

New Jersey's tax policies should also give the Gardens project an advantage, at least initially, over its closest off-price competitor, Woodbury Common, which is 50 miles north of the city near Exit 16 of the New York State Thruway.

According to Mr. Glimcher, half the sales at the Ikea home furnishings store a stone's throw from Jersey Gardens are to New Yorkers seeking to avoid higher taxation. The changes in New York's tax laws do not affect furniture sales. AND the delay in the Mills project encouraged many retailers that had been hesitating over which mall to join to sign up with Jersey Gardens, Mr. Latella said. ''We had projected that they would be 80 percent leased at opening, but I hear they are well ahead of that,'' he said. Glimcher said it had leases or letters of intent for 90 percent of the mall's retail space.

Jersey Gardens has been built on contaminated land known as a brownfield that was covered by 1.3 million cubic yards of clean mud dredged from nearby Newark Bay. Changing the dingy, industrial nature of the immediate neighborhood was a major goal of the mall's layout and furnishings, said David Rockwell of the Rockwell Group, the project's architect.

''The idea was to turn some of the public spaces into a neighborhood park,'' Mr. Rockwell said. Large skylights in the roof are intended to bring as much natural light as possible into the mall's walkways and to provide energy for plants growing inside.

''Large topiary walls will move through the project as almost vertical gardens,'' he said. The ivy and other vines will be permanent, he said, but other plantings will change with the seasons to give a fresh look to repeat customers.

He said particular attention had been given to the food court, which will have spaces separated from one another and have individual entrances. ''There is an incredible sameness'' to most food courts, Mr. Rockwell said. ''We wanted to do a series of living rooms.'' Where interior lighting is required in the public spaces, individual lights in glass globes hang at different distances from the ceiling.

Outlet malls like the Mills operations and Woodbury Common have become tourist destinations, with Potomac Mills asserting that it is the biggest tourist attraction in Virginia. Catering to tour groups, the malls have been built with separate entrances and parking areas for buses and foreign language speaking hosts to assist tour groups.

Mr. Glimcher said Jersey Gardens planned to exploit its proximity to Newark Airport and its growing number of international flights. ''We will have a full-time travel director,'' he said, ''who will go around the world and book groups who will fly into the airport.''